PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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The HC allowed the writ petitions and held that assessees possess a statutory right to apply to the ITSC/Interim Board for settlement under the amended Sections 245A-M. The Court concluded the Finance Act, 2021, though retrospective, does not expressly or by necessary implication abrogate vested rights to file settlement applications between 01.02.2021 and 31.03.2021; the amendments merely rendered the ITSC inoperative and transferred pending matters to the Interim Board. The respondents' 28.09.2021 order is to be read down so that the cut-off of 31.01.2021 is read as 31.03.2021. The petitioners' settlement applications filed on 22.03.2021 are therefore validly pending for consideration by the Interim Board.
The HC allowed the writ petitions and held that assessees possess a statutory right to apply to the ITSC/Interim Board for settlement under the amended Sections 245A-M. The Court concluded the Finance Act, 2021, though retrospective, does not expressly or by necessary implication abrogate vested rights to file settlement applications between 01.02.2021 and 31.03.2021; the amendments merely rendered the ITSC inoperative and transferred pending matters to the Interim Board. The respondents' 28.09.2021 order is to be read down so that the cut-off of 31.01.2021 is read as 31.03.2021. The petitioners' settlement applications filed on 22.03.2021 are therefore validly pending for consideration by the Interim Board.
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